Opinion
6567-20S
10-06-2021
Tsehay Taddesse Joerg & Norton Ciccone Joerg Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley Chief Judge.
Petitioners in this case seek review of a notice of deficiency issued with respect to the 2017 tax year. A copy of the notice of deficiency on which this case is based is attached to the petition. However, upon further review, it appears that the notice of deficiency attached to the petition was issued only to petitioner Tsehay Taddesse Joerg. No notice of deficiency issued to petitioner Norton Ciccone Joerg has been produced by petitioners or respondent.
This Court is a court of limited jurisdiction. In a case seeking redetermination of a deficiency, the jurisdiction of the Court depends on the issuance of a valid notice of deficiency and the filing of a Tax Court petition within 90 days after the notice of deficiency is mailed (not counting Saturday, Sunday, or a legal holiday in the District of Columbia as the last day). See Internal Revenue Code section 6213(a). As the record does not contain a copy of a notice of deficiency issued to Norton Ciccone Joerg, it appears that the Court may lack jurisdiction in this case with respect to petitioner Norton Ciccone Joerg.
Upon due consideration, it is
ORDERED that, on or before October 27, 2021, the parties shall show cause in writing why so much of this case relating to petitioner Norton Ciccone Joerg should not be dismissed for lack of jurisdiction on the grounds that no notice of deficiency for tax year 2017 sufficient to confer jurisdiction on this Court was issued to Norton Ciccone Joerg.
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